Bassett v. Arizona
Headline: Court declines review of an Arizona case about mandatory life-without-parole for a juvenile, leaving pre-2014 parole-free sentences in place despite a Justice’s dissent urging reversal.
Holding: The petition for certiorari is denied, so the Supreme Court will not review the Arizona court’s rejection of Bassett’s postconviction challenge to his juvenile life-without-parole sentences.
- Leaves some people sentenced as juveniles in Arizona serving life without parole with no parole option.
- Keeps Arizona’s state-court denial in place because the Supreme Court refused to review it.
- 2014 parole 'fix' does not retroactively help all "natural life" prisoners.
Summary
Background
Lonnie Bassett was 16 when he shot and killed two people in 2004. He was convicted of two counts of first-degree murder and in 2006 received one “natural life” term and a consecutive “life” term. At that time Arizona had abolished parole for felony convictions (1994–2014), so the judge had no parole-eligible sentence to give. The Arizona Supreme Court denied his postconviction challenge, and the Supreme Court declined to review the denial.
Reasoning
The dissenting Justice explains the main question as whether Arizona’s sentencing system gave judges real authority to impose less than life without parole for crimes committed by children. Citing the Court’s earlier rulings, she says the Constitution requires a sentencing procedure that lets the judge consider youth and impose a parole-eligible sentence when appropriate. Arizona agreed parole-eligibility is required but argued three defenses: a widespread judicial mistake about state law, that Bassett’s age was considered at sentencing, and a 2014 legislative fix. The dissent rejects those defenses because Arizona law at the time left no option other than life without parole, so the sentencing court lacked true discretion; she would therefore grant review and reverse.
Real world impact
Because the high Court declined review, the Arizona decision stands for now and Bassett’s sentences remain in place. The dissent notes dozens of people in Arizona who were sentenced as juveniles remain without a meaningful path to release, and the 2014 change does not help everyone (it applies to some "life" terms but not all "natural life" terms).
Dissents or concurrances
Justice Sotomayor, joined by Justices Kagan and Jackson, dissented from the denial and would summarily reverse the Arizona court, saying the state’s scheme conflicted with this Court’s precedents.
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